Finding Text
Finding 2023-003: Period of Performance
Federal Program: ALN 19.701
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation):
According to 2 CFR Part 200, Uniform Guidance, §200.309 - Period of Performance, Federal
awards must comply with the specified period of performance outlined in the award documentation.
The period of performance defines the timeframe during which the recipient may incur costs and
complete the project or program objectives.
Condition: During the audit period, the Global Center had two active awards serving nearly
identical purposes. The first award concluded in September 2023, at which point the follow-on
award commenced. In July 2023, the Global Center incurred an expense, believing it could be
charged to the follow-on award. The Global Center requested authorization from the donor to
charge the cost to the award, even though it was incurred prior to the commencement of the period
of performance. While awaiting confirmation from the donor, the Global Center went ahead and
billed the expense to the award. The donor, however, took nearly a year to respond and ultimately
ruled the cost unallowable. The Global Center subsequently reclassified the cost out of the award.
Cause: Administrative delays and miscommunication with the donor.
Effect or Potential Effect: As a result of initially recording an expense incurred prior to the
commencement of the period of performance before it had specific authorization to do so, the
Global Center inadvertently drew down funds for this unapproved cost.
Questioned Costs: None noted
Context: By recording the expense before receiving donor confirmation, the Global Center risks
incurring and claiming costs outside of the allowable period for reimbursement.
Identification as a Repeat Finding: Not applicable
Recommendation: The Global Center should refrain from recording any expenses outside the
period of performance until written approval is received from the donor, ensuring compliance with
award guidelines.